Williams v. Taylor

In 1986, Terry Williams (defendant) was sentenced to death for robbery and murder after a jury trial in Virginia state court. At the penalty phase for Williams’s trial, Williams’s counsel emphasized only Williams’s voluntary confession to the crime, and the prosecution (plaintiff) focused on depicting Williams as a serious threat to society. In 1988, the same judge that presided over Williams’s trial reviewed Williams’s petition for state collateral relief. At an evidentiary hearing, Williams presented extensive mitigating evidence that his trial counsel had failed to present, including evidence of Williams’s severe child abuse, sixth-grade education, intellectual disability, and very positive responses to highly structured environments like prison. The trial court held that Williams had received ineffective assistance of counsel (IAC) during the penalty phase of trial. The Virginia Supreme Court rejected the trial court’s recommendation of a new sentencing hearing, finding that the trial court incorrectly applied the United States Supreme Court’s IAC caselaw. The Virginia Supreme Court reasoned that because Williams’s newly presented mitigating evidence would have barely impacted the prosecution’s evidence of future dangerousness, there was no reasonable possibility that the additional evidence would have affected the jury’s death-sentence recommendation. Williams then filed a federal habeas petition, and the federal district court granted Williams’s petition. The United States Court of Appeals for the Fourth Circuit reversed, finding that the district court did not follow the Antiterrorism and Effective Act of 1996’s (AEDPA) requirements for federal habeas courts’ deference to state-court decisions. The United States Supreme Court granted certiorari.